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HMRC internal manual

Fraud Civil Investigation Manual

From
HM Revenue & Customs
Updated
, see all updates

Where CDF offer is made up to 29 June 2014: the initial meeting: questions to be asked concerning the taxpayer’s private affairs

Whether the meeting with the taxpayer is to:

  • clarify an Outline Disclosure
  • commission a disclosure report or
  • when dealing with a denial or non cooperation case,

in addition to questions concerning the taxpayers’ business affairs, you should consider asking questions about their private financial affairs where you believe this is appropriate.

This is to:

  • understand the context in which the disclosure is made
  • explore the possibility of other tax risks
  • understand the linkages between the taxpayer’s personal and business affairs
  • close off any unsubstantiated explanations of accumulated wealth and
  • ascertain the living standards.

All of which will help you validate the contents of the disclosure report.

If there is more than one taxpayer present they should be reminded again of their entitlement to confidentiality. If taxpayers insist on being seen together then they may be seen on that basis, but if you feel that it is appropriate you should ask to speak to them separately.

In some instances you might well conclude that it is preferable to see the taxpayers separately at some point in the interview. For example, to give them the opportunity to talk freely in case there is some matter they do not want to relate in front of a partner, co-director or spouse.